IBA Annual Conference Miami 2022

30 Oct - 4 Nov 2022

Rooms 230-231, Level 2

Session information

Is private equity and venture capital under siege? Taxation of investment vehicles and carried interest, and application of anti-hybrid rules
Rooms 230-231, Level 2
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Taxes Committee (Lead)


Recurring initiatives in multiple jurisdictions to amend the taxation of partnerships leads to opportunities and risks for the industry. This applies to sponsors, investors, and the vehicles themselves facilitating or obstructing cross-border investments. Different approaches for how to tax carried interest are in place in the countries of sponsors. Is the pressure on policymakers behind the preferred treatment of sponsor return as capital gain, rather than as ordinary income, the same in all countries? And for investors: pension and retirement funds, sovereign funds, individuals, and corporate treasuries? What about the promoting entity jurisdiction, will source countries respect the look-through nature of investment vehicles and tax investors accordingly? The anti-hybrid rules should give answers, but often cause more confusion and complexity.

Session / Workshop Chair(s)

Brenda Coleman Ropes & Gray, London, England
Ron Nardini Vinson & Elkins, New York, New York, USA


Robert Gaut Proskauer, London, England
Thierry Lesage Arendt & Medernach, Luxembourg City, Luxembourg
Yuval Navot Herzog, Tel Aviv, Israel
David Weisner Brown Brothers Harriman, Boston, Massachusetts, USA